Time-barred reassessment notice under Section 148 for Assessment Year 2015-16 was set aside with consequential relief.

A reassessment notice under Section 148 for Assessment Year 2015-16, issued on or after 1 April 2021, was treated as time-barred in light of the concession recorded before the Supreme Court that such notices for that assessment year could not survive. Once the assessment year was identified as 2015-16, no further adjudication was required, and the writ petition was allowed on that limited basis. The notice was set aside together with all consequential actions.

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Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 for Assessment Year 2015-16 was barred by time and liable to be quashed.

Analysis: The notice concerned Assessment Year 2015-16 and was issued on or after 1 April 2021. In view of the concession recorded before the Supreme Court that reassessment notices for Assessment Year 2015-16 are time-barred, no further adjudicatory exercise was necessary once the assessment year was found to be 2015-16. The revived writ petition was therefore required to be decided on that limited basis.

Conclusion: The notice under Section 148 was held to be time-barred and was set aside, along with all consequential actions.

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